Regulatory Note | ESPR, Digital Product Passports, and the Textile Sector
Prepared for executive and compliance audiences.
ESPR Is Enacted Law, Not a Policy Draft
The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR) has been in force since 18 July 2024.
This is binding EU law. The framework is adopted and active.
What remains product-specific is not whether obligations will apply, but the operational detail per product group, to be defined through delegated acts.
ESPR establishes the legal architecture for lifecycle sustainability, traceability, and transparency for physical goods placed on the EU market. Compared with the former Ecodesign Directive, it materially expands scope beyond energy performance to include durability, repairability, substances of concern, and end-of-life handling.
The Digital Product Passport (DPP) Under ESPR
Under ESPR, the Digital Product Passport (DPP) is a core compliance mechanism supporting traceability, lifecycle management, market surveillance, and enforcement.
The DPP framework is designed to carry structured product data, including:
- materials and origin-relevant information
- substances of concern
- repair, reuse, and end-of-life handling data
- Unique identifier on item level
Product-group delegated acts will define the exact data fields, formats, access rights, identifiers, and timing. They will also specify how data carriers and product identification are implemented for each regulated category.
The direction is settled: the DPP is embedded in enacted law. Delegated acts finalize product-level execution.
Textiles and Apparel: Priority 1 and the Working Plan Path
In the ESPR Working Plan 2025-2030, textiles and apparel are ranked as Priority 1 (Section 2.2), with DPP-related implementation set from 2027 (Section 3.2 and Table 2.2.1).
On the current regulatory path:
- Textile delegated act set in the Working Plan for late 2026
- DPP obligations set in the Working Plan from early 2027
- Approximate 18-month phase-in period expected
The delegated act is pending. However, the Working Plan reflects adopted policy direction, and there is no signal of deviation from this trajectory.
Destruction Ban: Fixed Dates Already in Force Under ESPR
Separate from DPP rollout, ESPR already establishes a binding prohibition on destroying unsold consumer textile-related goods.
- Large enterprises placing apparel, clothing accessories, or footwear on the EU market are prohibited from destruction from 19 July 2026
- Medium-sized enterprises are subject to the same prohibition from 19 July 2030
These dates are fixed in law and do not depend on textile DPP delegated-act publication.
Why This Is Also a Data Architecture Issue
For leadership teams, this is not only a legal interpretation question. It is a systems design and evidence readiness problem.
Practical readiness requires a dual model:
- Item-level identity and passport linkage for products in scope of DPP obligations
- Batch, SKU, and inventory-flow traceability for redistribution, donation, recycling, and non-destruction controls
The destruction-ban regime increases pressure for defensible records on quantities, handling routes, and rationale in both internal governance and external disclosures.
Teams relying on fragmented spreadsheets, disconnected ERP exports, or delayed manual reconciliation face avoidable execution risk once supervisory scrutiny increases.
What This Means Operationally
Two obligations are progressing in parallel:
- The destruction ban has enacted, fixed legal dates
- DPP obligations are structurally fixed under ESPR, with textile-level execution detail pending delegated-act finalization
Organisations that wait for delegated-act publication to begin architecture work will compress implementation into a narrow window where resources will be limited.
A very short window for introducing reliable product identifiers, lifecycle event capture, access governance, and audit-ready traceability across suppliers and product lines.
Timeline at a Glance
| Date | Event | Status |
|---|---|---|
| 18 July 2024 | ESPR enters into force | Enacted |
| 19 July 2026 | Destruction ban applies to large enterprises | Enacted |
| Late 2026 | Textile delegated act | Set in Working Plan |
| Early-Mid 2027 | DPP obligations begin for textiles | Set in Working Plan |
| 19 July 2030 | Destruction ban applies to medium enterprises | Enacted |
Confirmed Law vs Working Plan and Delegated Detail
Enacted and binding
- Regulation (EU) 2024/1781 (ESPR), in force since 18 July 2024
- DPP established as a core compliance instrument under ESPR
- Prohibition on destruction of unsold consumer goods in relevant textile categories
- Large enterprises: from 19 July 2026
- Medium-sized enterprises: from 19 July 2030
Pending delegated act detail for textiles, decided in Working Plan
- early/mid-2027 expected legal start date for textile DPP obligations
Primary References
- Regulation (EU) 2024/1781 - Ecodesign for Sustainable Products Regulation
- European Commission - Ecodesign for Sustainable Products Regulation overview
- ESPR Working Plan 2025-2030
Next Step for Leadership Teams
DeviceStamp supports brands and manufacturers in building DPP-ready data architecture with verifiable product identifiers, lifecycle records, and interoperable structures ahead of delegated-act deadlines.
Move from interpretation to execution
Build the data and identifier layer before the compliance window compresses.
Legal disclaimer: This note is provided for general informational purposes and does not constitute legal advice. It reflects publicly available EU legal sources and policy documents as of 17 February 2026. Organisations should obtain independent legal counsel to assess how Regulation (EU) 2024/1781 and related delegated acts apply to their specific products, markets, and operating model.